S. 12AA : Procedure for registration –Trust or institution-Application not disposed of within six months — Registration cannot be deemed to be granted —interpretation of taxing statutes — Literal Interpretation- Meaning of deemed [ S.12AA(2) ]
S. 12AA : Procedure for registration –Trust or institution-Application not disposed of within six months — Registration cannot be deemed to be granted —interpretation of taxing statutes — Literal Interpretation- Meaning of deemed [ S.12AA(2) ]
S. 12AA : Procedure for registration –Trust or institution- Charitable purpose- Trust would be hit by proviso to Section 2(15) cannot be the ground for cancellation of registration [ S.2(15) 12AA(3) ]
S. 12A : Registration –Trust or institution- Order granting o rejecting of application to be passed within 6 Months — Application Filed On 17-9-1999 decided on 31-10-2001 beyond period of six months —Registration shall be deemed to have taken effect after six months from date of filing application — Grant of registration does not ipso facto entitle to exemption . [ S.2(15) 11, 12A ]
S. 12AA : Procedure for registration –Trust or institution-
Association of third party administrators — Dominant purpose of Institution Charitable — Ancillary purposes not charitable —Entitled to registration [ S.(2(15) ]
S. 12AA : Procedure for registration –Trust or institution-Charitable purpose —Objects of Trust and activities are in furtherance of objects -Newly formed trust – Registration cannot be refused on the ground that no activities were carried on – Remand of matter for fresh disposal of matter – Order of High Court is affirmed . [ S.2 (15) 11(1)(d) 12A, 13 ]
S. 11 : Property held for charitable purposes – Application of income – Commercial principles- Adjustment of excess expenditure of earlier year against income of current year amounts to application of income .[ S .2(15) 11(1) (a) ]
S. 10B: Export oriented undertakings – Interest on delayed payment for goods exported and goods sold Locally — Exemption available only for interest on delayed payment for Exports. [ S.10B(4) ]
S.10(23C: Educational Institution —Trust deed disclosing profit motive — Not entitled to exemption [ S.10(23C)(vi)
S. 9(1)(i): Income deemed to accrue or arise in India – Business connection -Non-Resident —Permanent Establishment — Telecasting Sports Events – Principal to principal basis – Income earned not assessable in India — DTAA -India – Mauritius [ Art .5 ]
S. 2(22)(e):Dividend – Deemed dividend-Money lending formed substantial part of business – Loan not assessable as deemed dividend .